On October 12, 2017, Global Affairs Canada published a Consolidated Special Economic Measures Act Sanctions List. Before today, Canadian companies had to review each regulation promulgated under the Special Economic Measures Act when conducting due diligence. However, and this is important, the Global Affairs Consolidated Special Economic Measures Act Sanctions List does not include sanctions under the United Nations Act. As result, it is still necessary to review each regulation promulgated under the United Nations Act.
The Consolidated SEMA Sanctions List was last updated on October 7th. The Venezuela SEMA sanctions are included. However, if the Consolidated SEMA Sanctions List is not updated when new SEMA sanctions are imposed, the list will not be useful for very long.
The Consolidated SEMA List has been requested by Canada’s economic sanctions lawyers for years (but we asked for all economic sanctions lists to be consolidated into a user-friendly list). In April 2017, the House of Commons Standing Committee on Foreign Affairs and International Development (FAAE) issued a report entitled “A Coherent and Effective Approach: Canada’s Economic Sanctions Regimes: Sergei Magnitsky and Beyond” in which it recommended the following: